PRIVACY POLICY
SECOND PHONE NUMBER APP
Effective date: July 1, 2026
You can see our previous Privacy
Policy here
and here.
TABLE OF CONTENTS
●
Section 1: Personal Data We Collect and How We
Collect It
●
Section 2: Personal Data You Provide To Us
Directly
●
Section 3: Personal Data And Other Data We
Collect Automatically
●
Section 4: The Purposes and Our Legal Bases For
Processing Your Personal Data
●
Section 5: To Whom We Disclose Personal Data
●
Section 6: Cookies, Software Development Kits,
and Other Tracking Technologies
●
Section 7: Your Rights In Relation to Your
Personal Data
●
Section 8: Your Choices About Our Communications
With You
●
Section 11: Cross-Border Data Transfers
●
Section 12: Children’s Privacy
●
Section 13: Third-Party Websites and Services
●
Section 14: How to Contact Us, EEA/UK
Representative, and Data Protection Officer
●
Section 15: Changes to Our Privacy Policy
|
TL;DR:
This
Privacy Policy explains what personal data we collect about you in the Second
Phone App, how we use it, with whom we share it, and what rights you have. By
using the App you agree to the processing described here. |
This Second Phone App Privacy Policy (“Privacy Policy”) is delivered on behalf of Municorn Limited (“we”, “us”, and “our”) and
governs the Personal Data (as defined below) collected from or processed about
you when you use the Second Phone Number: 2nd eSIM App mobile
application, which provides an easy way to call all over the world on the go (“Second Phone App”, “App”),
including by downloading, installing, registering with, accessing or otherwise
using the application (collectively referred to herein as “Use”).
We provide this Privacy Policy to explain our practices for
collecting, using, processing, and disclosing the Personal Data we process
about Second Phone App users (“users”,
“you”, or “your”, as applicable), and to tell you about the rights you may
have in relation to your Personal Data and choices you may be able to make in
relation to it.
By Personal Data, we mean (i) information that is associated
with an identified or identifiable natural person, and (ii) protected as
personal data under applicable data protection laws.
Please read this Privacy Policy
carefully to understand our privacy practices. We also encourage you to get
acquainted with our Terms of Use to understand how we provide services to you.
By accepting this
Privacy Policy, you acknowledge that you understand and agree to the processing
of your Personal Data and other information as described in this Privacy Policy.
If you do not
wish to have your data processed in accordance with this Privacy Policy, please
refrain from using the Second Phone App.
Questions?
If you have any questions about this Privacy Policy or
Second Phone App, please contact our Support Team Chat in the App or on our
website. If the chat is not available, you may contact us at second-phone-support@municorn.com. For additional contact information,
please see Section
14: How to Contact Us.
U.S. State Supplements:
This Privacy Policy is designed to
comply with data privacy laws across the United States, including:
·
California
Consumer Privacy Act (CCPA),
·
Colorado
Privacy Act (CPA),
·
Connecticut
Data Privacy Act (CTDPA),
·
Virginia
Consumer Data Protection Act (VCDPA),
·
Texas Data
Privacy and Security Act (TDPSA),
·
Tennessee Consumer Privacy Act
(TCPA),
·
Oregon
Consumer Privacy Act (OCPA) and other applicable state laws.
If you are a resident of California,
please see our California
Notice at Collection and Privacy Notice,
which provides detailed information about your rights and additional
disclosures specific to California.
If you are a resident of Colorado,
Connecticut, Virginia, Texas, Oregon, Tennessee, or any other U.S. state with
privacy laws, please see our U.S. State Privacy Supplement (Non-California). The rights granted to you under these laws are also
outlined in this Privacy Policy. These include:
·
The right to
access, correct, delete, or receive a copy of your personal data.
·
The right to
opt out of the sale or sharing of your personal data, targeted advertising, and
profiling with legal or significant effects.
You may exercise these rights by
contacting our support team via chat in the App or on our website. If the chat
is not available, you may contact us at second-phone-support@municorn.com or through the in-app privacy
settings, where available.
|
TL;DR:
We
collect personal data in three ways: directly from you when you provide it,
automatically when you use the App (e.g., usage and device data), and from
third parties such as service providers and partners. |
We may collect Personal Data from
and about you:
●
Directly from you when you provide
it to us.
●
Automatically when you Use Second
Phone App. Information collected automatically may include Usage details and
internet protocol (“IP”) addresses.
●
From third parties, for example, our
service providers, partners and vendors.
|
TL;DR:
When
you use the App, you may provide us with information directly — photos you
upload, contacts you add, messages you send to us, and similar data. Please
do not upload sensitive information voluntarily, as we cannot control or take
responsibility for it. |
You may provide Personal Data to us
directly, or to service providers that act on our behalf, when you Use Second
Phone App. The Personal Data you provide depends on which features of Second
Phone App you Use and how you interact with the app.
●
●
Photos that you upload to Second Phone App. If you grant us permission to access your camera or your
device’s photo library, we will process the photos you select to upload to
Second Phone App to provide features of the app that you choose to Use.
●
If you contact us or communicate
with us, we will collect and receive records
and copies of your correspondence with us and contact details that you have
provided us while making your inquiries (such as your name, postal
addresses, email addresses and phone numbers or any other identifier by which
you may be contacted).
●
App Contacts. When you choose to add a new contact
to the App Contacts, you may provide information such as a name, phone number,
photo, or other details. We process the contacts you add to the App Contacts to
enable core functionality of the application (e.g., making calls, sending
messages), and to store and display the contacts you have created in your App
Contacts. The processing of App Contacts is based on our legitimate interests
in providing you with the core functionality of the Second Phone App.
●
Phone Contacts. You may choose to grant the Second Phone App access to your
device’s Phone Contacts. This access is optional and controlled by your
device’s operating system settings. If you grant access, the Second Phone App
may display and use your Phone Contacts locally on your device (e.g., for
making calls or sending messages). These Phone Contacts are not uploaded to our
servers or otherwise transferred outside your device.
●
Mobile carrier and other related
data.
● Sensitive data. We do not intentionally
use or process sensitive data beyond what is necessary to provide the App's
core functionality. Sensitive data may include, but is not limited to,
financial, biometric, or other confidential information.
Sensitive information is provided
solely at the user’s discretion and under their control. If sensitive data is
uploaded voluntarily, it is done at the user’s own responsibility, and we
encourage users to avoid including such data in their documents and/or messages.
By uploading documents and sending messages, you
acknowledge that the decision to include sensitive information is yours, and we
are not liable for any sensitive data uploaded without request or consent.
|
TL;DR:
When
you use the App, we (and our partners) automatically collect data such as log
files, device and app information, geolocation (country/state level), in-app
events, subscription details and, with your consent, your advertising
identifier. |
When you Use Second Phone App, we or
third parties we permit to do so, may automatically collect certain
information, including Personal Data, from you (this is subject to your consent
where this is required by law). The information collected from you automatically
when you Use Second Phone App may include:
· Log file information. Log file information is automatically reported by your browser
each time you make a request to access (ie, visit) a web page or app. It can
also be provided when the content of the webpage or app is downloaded to your
browser or device. When you use Second Phone App, our servers automatically
record certain log file information, including your web request, IP address,
browser type, referring / exit pages and URLs, number of clicks and how you
interact with links on the Second Phone App, domain names, landing pages, pages
viewed, and other such information. We may also collect similar information
from emails sent to our Users which then help us track which emails are opened
and which links are clicked by recipients. The information allows for more
accurate reporting and improvement of our services.
·
Subscription
and device data.
Information related to your subscription and device used for technical
authorization.
·
Marketing
and cookies data. Collected
through cookies and analytics services integrated into the app.
· Device information. Information about your mobile device and internet connection,
including your IP address, the device’s unique device identifier, operating
system and version, mobile network information, device type and device
language.
· App and country information. Information regarding the version of the app that you are using
and the country version of the app store from which you downloaded Second Phone
App.
●
Geolocation data.
The state or country associated
with your IP address.
●
In-app events. When you use our App, analytics tools automatically record your
activity information (tutorial steps, levelling up, payments, in-app purchases,
custom events, progression events, method of limiting the processing of user
data).
●
Session replay and interaction data. We use session replay technology (such as Amplitude Session
Replay) to better understand how users interact with our services and to
improve the user experience. This technology may capture user interactions,
including taps, clicks, scrolling activity, navigation patterns, and screens
viewed, to help us identify usability issues, troubleshoot technical problems,
and optimize our services.
●
Usage details. Details of your Use of Second
Phone App, including frequency of Use, areas and features of the application
that you access and information regarding engagement with particular features
of the app.
●
Details about your in-app purchases.
For example, details regarding the time you made certain purchases.
●
Payments. When enabling payment processing,
you will integrate with Stripe. The payment account details are stored by
Stripe, not by us. Payment links or QR codes may be generated and shared to
facilitate client payments.
●
(If you have provided your consent) IDFA or Android Advertising ID, whichever is applicable to your device. If you want to disable
the collection of IDFA and/or Android Advertising ID by Second Phone App,
please follow the instructions below.
If you use an iOS device:
1.
2.
Tap to turn off or turn on
permission to track for Second Phone App.
If you use an Android device:
1.
2.
Navigate to “Privacy” > “Ads”
3.
Tap “Delete Advertising ID”
4.
Tap it again on the next page to
confirm.
Other than with respect to Image
Data, we and third parties we engage may use cookies, Software Development Kits
(SDKs), and other tracking
technologies to automatically collect the Personal Data set forth above. For
more information regarding our use of these technologies, please see Section 6:
Cookies, Software Development Kits, and Other Tracking Technologies.
We may use your Personal Data for a
variety of purposes depending on the category of Personal Data and the way you
Use and interact with the Second Phone App, including the following:
●
To present to you and others with
Second Phone App and its contents and any other information, products or
services that you request from us, including to provide various features of the
app and its functionality. We do so to provide you with the services according to our contractual
obligation.
●
To carry out our obligations and
enforce our rights arising from any contracts entered into between you and us
in relation to Second Phone App (e.g., the Terms of Use).
This is for the performance of our contract with you and for our legitimate
interests in performing and enforcing our contracts with you. To customize our
product and service offerings to you, for example, offering pricing
personalization and discounts. In doing so, we make automated decisions using
device type and device language data. Where required by law, we rely on your
consent to offer such personalization and/or offer you the opportunity to opt
out.
●
To provide you with customer and
technical support, investigate your concerns, respond to your inquiries and to
monitor and improve our responses to your and other users’ inquiries in
relation to Second Phone App. It is our legitimate interest to provide you with
high-quality support.
●
To communicate with you, such as to
notify you about changes to Second Phone App or any products or services we
offer or provide through Second Phone App, including by sending you technical
notices, notices about your account/subscription, including expiration and
renewal notices, updates, security alerts and support and administrative
messages, which we may send through an in-app or a push notification (you may
opt-out of push notifications by changing the settings on your mobile device).
It is our contractual obligation to keep you informed about your subscription
and your account and otherwise in our legitimate interests of keeping you
informed about your Second Phone App account.
●
To conduct research, analytics and
monitor performance and other metrics regarding Second Phone App and your Use
of Second Phone App. This may include data regarding the total number of users
of our app, traffic, and demographic patterns related to the use of our app.
Where this data is collected through the technologies described in Section 6 and where required by law, we rely on your consent; otherwise, it
is our legitimate interest to conduct analytics as it helps us understand our
business metrics and improve our product. For marketing and analytics purposes,
we may use aggregated and anonymized data related to your usage patterns. This
data is used to enhance the app’s features and provide tailored promotional
content.
●
To improve, test, and monitor the
effectiveness of Second Phone App. It is our legitimate interest to conduct
such analyses to understand our product and business metrics.
●
Geolocation data is collected in an
aggregated, non-identifiable format for analytics and service enhancement. We
do not use your precise location for any marketing purposes without your
explicit consent.
●
To provide personalized content and
information to you in relation to Second Phone App and so that we, and third
parties on which we rely, can advertise to you. This may include using your
Personal Data to build advertising audiences that we believe are similar to our
user base, serving online ads to you, or engaging in other forms of
advertising. Where required by law, we rely on your consent to engage in such
activities and/or
●
To send marketing and promotional
communications to you, such as via email, push notification or in-app messaging
either with your consent or as otherwise permitted by law. Please see Section 8:
Your Choices About Our Communications With You for more information.
●
In any other way as we may describe
when you provide the information or otherwise at your direction or with your
consent.
●
As permitted or required by law,
including for auditing, fraud and security monitoring purposes.
|
TL;DR:
We
share personal data with service providers (e.g., Microsoft Azure, Telnyx,
Yuno), analytics and advertising partners (e.g., Amplitude, AppsFlyer,
Firebase, Facebook Pixel, Google Ads), payment processors (Stripe, Apple
Pay), and where required for legal reasons or in connection with corporate
transactions. Some recipients are outside the EU/UK — see Section 11 for safeguards. |
We may disclose the information we
process about you, including any Personal Data, as follows:
●
We may disclose your Personal Data,
and other data and collected information to third-party organizations such as contractors, business partners, service
providers, and vendors that we use to support our business and who assist
us in providing Second Phone App. Such service providers may include:
o
o
Telnyx LLC,
our cloud communications provider and data processor
– subject to their Terms and Conditions of Service,
o email delivery providers.
●
We may disclose your Personal Data
to third-party analytics providers and
advertising partners or otherwise permit them to collect or access it. For
more information, please see Section 6: Cookies, Software Development Kits, and Other Tracking
Technologies.
These analytics providers may
include:
o Amplitude – subject
to their Terms of Service.
o AppsFlyer – subject
to their Terms of Use.
o Firebase – subject
to their Terms of Service.
o Appfigures – subject
to their Terms of Use.
o Facebook Pixel – subject to their Facebook
Terms and Policies.
o Google Ads – subject to
their Google Ads Terms and Conditions.
o LeadProm Media (trading as
Merchanto) – subject to
their Terms and Conditions.
o Twilio SendGrid – subject to
their Terms of
Service.
o Yuno - subject to their Terms and Conditions.
o Braze – subject to their Terms of
Service.
●
We may disclose your Personal Data
in the event that we or any of our affiliates, subsidiaries or lines of
business is merged, acquired, divested,
financed, sold, disposed of or dissolved, including in the course of a transaction like a merger,
divestiture, restructuring, reorganization, acquisition, bankruptcy,
dissolution, or liquidation. In such cases, your Personal Data and any other
collected information may be among the items sold, transferred, or otherwise
disclosed as part of that transaction or proceeding.
●
We may disclose your Personal Data in response to legal requests and for
purposes of preventing harm. We may access, preserve and share your
information in response to a legal (like a search warrant, court order or
subpoena), government or regulatory request if we have a good faith belief that
the law requires us to do so. This may include responding to legal, government
or regulatory requests from jurisdictions where we have a good faith belief
that the response is required by law in that jurisdiction, affects users in
that jurisdiction, and is consistent with internationally recognized standards.
We may also access, preserve and share information when we have a good faith
belief it is necessary to: (i) detect, prevent and address fraud and other
illegal activity; (ii) protect ourselves, you and others, including as part of
investigations; and (iii) prevent death or imminent bodily harm. Information we
receive about you may be accessed, processed and retained for an extended
period of time when it is the subject of a legal request or obligation,
governmental investigation, or investigations concerning possible violations of
our terms or policies, or otherwise to prevent harm.
● Payments and Data Processing.
We do not collect, store, or directly
process sensitive payment details such as credit card numbers, expiration
dates, or CVV codes. All payment transactions are securely processed by
third-party payment providers, including Stripe and Apple Pay, in accordance
with their respective terms of service and privacy policies. We recommend
reviewing Apple Pay & Privacy and Stripe Privacy Policy for detailed
information. We do not access or retain any sensitive payment information
submitted through these payment forms.
When making a payment, your
payment information (such as card details, billing address, and other financial
data) is provided directly to the relevant payment provider and is processed
and stored by them in accordance with their own privacy policies and terms of
service.
While payment details are exclusively processed
by these providers, we may process limited metadata related to transactions.
This includes transaction IDs, payment status, or non-sensitive identifiers
necessary for order confirmation, fraud prevention, service continuity, and
compliance with applicable legal or regulatory requirements. These activities
are carried out with strict adherence to data protection laws and solely for
purposes directly related to service provision.
For more information, please
review the Stripe Privacy Policy and Stripe Connected
Account Agreement and Apple Pay &
Privacy.
We encourage you to view the privacy
policies of Apple Pay and Stripe for comprehensive details on how your
sensitive payment data is managed. For questions or further assistance, please
contact our support team via chat in the App or on our website. If the chat is
not available, you may contact us by email at second-phone-support@municorn.com.
●
We will not share your opt-in to an
SMS campaign with any third party for purposes unrelated to providing you with
the services of that campaign. We may share your Personal Data, including your
SMS opt-in or consent status, with third parties that help us provide our
messaging services, including but not limited to platform providers, phone
companies, and any other vendors who assist us in the delivery of text
messages.
●
Some of the third-party service
providers and partners we share data with are located outside the EU/UK. Section 11: Cross-Border Data Transfers explains the safeguards we have in place to protect your personal
data during international transfers.
|
TL;DR:
We
and our partners use cookies, SDKs and similar technologies for analytics and
advertising. |
Analytics providers. When you Use Second Phone App, we and our
service providers, vendors, and partners, including third parties, may use
cookies
We may use cookies and similar technologies to collect information about
our customers’ interactions with our products and services in a manner that
allows us to reproduce and fix issues and to identify areas of improvement for
our products and services. Sensitive information is automatically masked, and
we do not use Session Replay to collect or store passwords, credit card
numbers, or other sensitive data. You
can opt out of the use of this software by contacting us at second-phone-support@municorn.com.
Interest-based Advertising. We
may partner with ad networks and other ad-serving providers that serve ads on
behalf of us and others on non-affiliated platforms. Some of those ads may be
personalized, meaning that they are intended to be relevant to you based on
information ad networks and ad serving providers collect about your Use of the
app over time, including information about relationships among different
browsers and devices. This type of advertising is known as interest-based
advertising.
Your Choices. Most
browsers and devices are configured to accept cookies and similar tracking
technologies automatically. You may be able to set your browser and device
options so to limit such technologies. You can visit the Digital Advertising
Alliance (“DAA”) Webchoices tool at www.aboutads.info
to learn more about this interest-based advertising and how to opt out of this
kind of advertising by companies participating in the DAA self-regulatory
program, and http://www.aboutads.info/appchoices
for information on the DAA’s mobile app opt-out program. You can also opt out
of receiving interest-based ads from members of the Network Advertising
Initiative (“NAI”) by visiting the NAI consumer opt-out page at http://optout.networkadvertising.org/?c=1#!/.
Opting out of receiving interest-based ads does not mean that you will no
longer receive ads from us, but rather that the ads will not be tailored to
your perceived interests.
Consumption Information. If we receive a refund request for an in-app purchase, we may provide
Apple with information about your in-app purchase activity.
This data may include:
·
User Status: the current status of your account.
We process this data solely to assist Apple in
evaluating refund requests, ensuring compliance with applicable laws and
regulations, including GDPR and CCPA. Users can withdraw their consent to this
processing at any time through the app settings or by contacting us.
Message Monitoring and Compliance. By using the Second Phone App, you agree to allow us and our partner,
Telnyx LLC, to collect, process, store, and monitor the content of messages
sent via phone numbers acquired through the app. This monitoring is conducted
to ensure compliance with messaging laws, regulations, and applicable policies,
including the Telnyx
Acceptable Use Policy and CTIA Messaging Principles. Additionally, it helps detect and prevent spam, abuse, illegal
activities, and fraudulent behavior, thereby maintaining a secure and lawful
messaging environment. For more detailed information, please refer to the
Second Phone App Messaging
and Calling Policy.
For users in the
European Economic Area, United Kingdom and United States. You can opt-out from processing of Personal Data via SDKs and
other tracking technologies through our support team chat in the App or on our
website. If the chat is not available, you may send a request to second-phone-support@municorn.com.
You may find that some parts of the app may not function properly if you
have refused certain tracking technologies, and you should be aware
that disabling certain
tracking technologies may prevent you from accessing
some of our content. Your choices are typically device and browser specific.
We honor Global Privacy Control
(GPC) signals as required by U.S. and international privacy laws. GPC is a
browser or device setting that allows you to control the sale or sharing of
your personal data. If GPC is enabled on your device, we will process it as a
valid opt-out request under applicable laws. For more information on enabling
GPC, please visit globalprivacycontrol.org.
Access,
modification, correction, and erasure.
You can send us an email at
EEA/UK
individuals. Individuals in the European
Economic Area (“EEA”) and the United
Kingdom (“UK”) have certain
statutory rights in relation to their Personal Data including under the General
Data Protection Regulation (Regulation (EU) 2016/679) (“EEA GDPR”) and the UK version of the EEA GDPR (“UK GDPR”) (collectively, the “GDPR”), including the rights specified
below. You can exercise these rights by contacting us (for contact information,
please see Section
14: How to Contact Us). We will do our
best to accommodate your request or objection but please note that not all
rights are absolute.
●
Access to your Personal Data: You
have a right to request information about whether we have any Personal Data
about you, and to receive a copy of such Personal Data.
●
Rectification of your Personal Data: You
are responsible for ensuring the accuracy of your Personal Data that you
provide to us. Inaccurate information may affect your experience when Using
Second Phone App features and our ability to contact you as described in this
Privacy Policy. If you believe that your Personal Data is incomplete or
inaccurate, you have a right to contact us and ask us to correct such Personal
Data.
●
Restriction of processing: You
also have the right to demand restriction of processing of your Personal Data,
for example, if you contest the accuracy of the Personal Data which inaccuracy
is verified by us.
●
Erasure of your Personal Data: In
certain circumstances, you may ask us to erase your Personal Data. Please be
aware that erasing some Personal Data may affect your ability to Use Second
Phone App.
●
Right to portability of your Personal Data: In certain circumstances, you have the right to request us
to receive any Personal Data you provided us in a structured, commonly used and
machine-readable format. You may further ask us to give that Personal Data to
another party.
●
Right to object to processing or otherwise using your Personal Data: You have the right to object at
any time to the processing of your Personal Data where such processing is based
on our legitimate interests, including the processing of your Personal Data for
direct marketing purposes.
Please note that this right does not apply to processing that is
necessary for the performance of a contract between you and us (such as
providing the core functionality of the App). However, objecting to certain
processing carried out based on legitimate interests, such as security, fraud
prevention, or service improvement, may affect our ability to provide some
features or services.
●
Right to withdraw your consent at any time: Where you may have provided your
consent to the processing of your Personal Data for a specific purpose,
you have the right to withdraw your consent for that specific processing at any
time. The withdrawal of your consent does not affect the lawfulness of the
processing based on your consent before its withdrawal.
●
Right to lodge a complaint with a supervisory authority: Subject to the GDPR, you have the right to lodge a complaint
with a local data protection authority in the country of your residence, where
you work or where an alleged infringement of the applicable data protection law
took place. Please see a list of EU member states’ supervisory
authorities here, and the UK’s supervisory authority (ICO) here.
To learn more about your privacy choices and rights regarding our
communication with you, please refer to Section 8.
Please keep in mind that in case of
a vague request to exercise any of the aforementioned rights we may engage with
you in a dialogue to ask for more details if so needed to complete your
request. In case this is impossible, we reserve the right to refuse to grant
your request.
Following the provisions of the
applicable law, we might also ask you to prove your identity (for example, by
requesting your username or some other proof of your identity) in order for you
to invoke the mentioned rights. This is made to ensure that no right of third
parties is violated by your request, and the mentioned rights are exercised by
an actual Personal Data subject or an authorized person.
Contact Data
Responsibility
When using the Second Phone App, you
may either:
· Grant access to your device’s phone contacts (“Phone Contacts”), or
· Manually add contacts directly into the App’s own
contact list (“App Contacts”).
You
represent and warrant that you have obtained all necessary consents,
authorizations, or other valid legal bases required under applicable law to
collect, use, and disclose any third-party personal data (including but not
limited to names, photos, telephone numbers, and similar information) that you
add to App Contacts or choose to share from your Phone Contacts via the App.
We
do not store your Phone Contacts on our servers, and we do not transfer them
outside your device. App Contacts may be stored within the App and, where
necessary, on our servers to enable the core functionalities of the Second
Phone App.
We
do not independently verify the lawfulness of your use of third-party contact
data and accept no responsibility or liability for your failure to comply with
applicable legal obligations regarding such data. You remain solely responsible
for ensuring the lawful processing of any third-party data you submit to or
through the App.
Prohibited
Content and User Responsibility
By using this App, you agree not to
upload any illegal, harmful, or unlawful content, including but not limited to:
·
Sensitive
personal data of third parties, such as
medical, financial, or biometric data, unless you have explicit consent,
·
And other types of information that
could be considered illegal.
Uploading such content is done at
your own risk and responsibility. You are solely responsible for ensuring that
the documents you upload do not contain illegal or unlawful material or content
you do not have the right to share.
In the event that we detect unlawful
content in the documents uploaded by users, we reserve the right to report such
content to the relevant authorities for further investigation. This may include
providing user-uploaded content or other relevant information to law
enforcement or other regulatory bodies, as required by law.
We do not bear responsibility for
any legal consequences arising from the uploading of prohibited content.
Manage your privacy rights. To enhance your experience, we provide in-app tools
to manage your privacy rights, such as:
·
Accessing
your personal data,
·
Deleting
your account and associated data,
·
Managing
consent for tracking and analytics technologies.
For additional assistance, contact
our support team via chat in the App
or on our website. If the chat is not available, you may contact us at second-phone-support@municorn.com.
Requests related to personal or
other data. We will process your requests related to personal data within 45 days from the date we receive them.
If additional time is required due to complexity or volume of requests, we may
extend this period by an additional 45
days. In such cases, we will notify you within the initial 45-day
period.
You may submit your request by
contacting our support team via chat in the App or on our website. If the chat is not
available, you may contact us at second-phone-support@municorn.com or through the app’s privacy settings.
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TL;DR:
Some
communications are necessary and cannot be turned off (account, subscription,
technical and security notices). Marketing emails are optional — in the
EEA/UK only with your consent, elsewhere on a legitimate interest basis where
permitted. You can unsubscribe at any time. Push notifications can be turned
off in your device settings. |
Necessary communications. If you are using the Second Phone App, you may receive certain
electronic communications from us (for example, in-app notices within the
Second Phone App, push notifications, or emails). These communications are necessary, and you cannot opt
out of receiving them, as they are required to perform
our contract with you and/or are sent based on our legitimate interest in
providing and maintaining the Second Phone App.
Such communications may include but
are not limited to: information related to your subscription and purchases
(including invoices and payment confirmations), account and settings, usage and
balance notifications, service updates, technical and security notices, and
updates to our Privacy Policy or Terms of Use.
Marketing
& Promotional Emails. Additionally, where permitted by
applicable law, we may send you marketing and promotional communications by
email relating to the Second Phone App, including promotional offers, product
tips, and announcements of new features.
For users located in the European
Economic Area and the United Kingdom, we will send you such marketing
communications only where you have provided your explicit consent, in
accordance with applicable data protection and ePrivacy laws. For users
located outside the EEA and the UK, including the United States, we may send
marketing communications based on our legitimate interests, where permitted by
applicable law.
You may opt out of receiving our
marketing and promotional emails at any time by clicking the unsubscribe link
included in any such email or by contacting our support team via chat in the
App or on our website. If the chat is not available, you may contact us at second-phone-support@municorn.com, without affecting the lawfulness of communications sent
prior to your opt-out.
You will then be removed from the
marketing email list; however, opting out of marketing emails will not affect
your receipt of non-marketing, service-related/transactional emails, which are
necessary for account administration and your use of the Second Phone App.
Please note that we do not use your precise location for any marketing purposes
without your explicit consent.
Push
Notifications. If you wish to opt out of push
notifications, you can do so through your mobile device settings by tapping
“Settings” -> “Notifications” -> Choose Second Phone App - > press the
toggle to allow or forbid push notifications from the app.
OTP Delivery. For authentication purposes, we may send you a One-Time Password
(OTP) via email. These emails are also processed via the providers mentioned
above and initiated only by user request (e.g., during login or identity
verification).
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TL;DR:
We
use reasonable technical and organizational measures (encryption, access
controls, secure servers, regular security testing) to protect your data. No
system is 100% secure — any transmission of data is at your own risk. If a
personal data breach occurs, we will assess, contain, remediate and, where
required by law, notify you and the authorities. |
We use reasonable and appropriate
information security safeguards to help keep your Personal Data and other data,
secure and, in an effort, to protect it from accidental loss and unauthorized
access, use, alteration and disclosure. We implement appropriate technical and
organizational measures to protect your personal data, including encryption,
secure servers, access controls, and regular security testing. We also require
our third-party service providers to maintain equivalent safeguards.
Unfortunately, the transmission of
information via the internet is not completely secure. Although we take
measures to do our best to protect your Personal Data, we cannot guarantee the
security of the collected information transmitted to or through the App or an
absolute guarantee that such information may not be accessed, disclosed,
altered, or destroyed. Any transmission of your Personal Data is at your own
risk. We are not responsible for the circumvention of security measures
contained in the App. Please understand that there is no ideal technology or
measure to maintain 100% security.
The safety and security of your
information also depend on you. For instance, we are not responsible for how
you choose to share the photos or other information processed in your Second
Phone App account, such as via social media services. We are not responsible
for the functionality, privacy, or security measures of any other organization.
In the event of a personal data
breach, we have procedures to promptly assess, contain, and remediate the
breach. Where required by law, we will notify the relevant data protection
authorities and affected users in accordance with GDPR and applicable laws.
If you believe your data has been
compromised, please contact our support team via chat in the App or on our
website immediately. If the chat is not available, you may contact us at second-phone-support@municorn.com.
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TL;DR:
We
keep your data only as long as needed: account data until you delete your
account; payment and transactional data for 7 years for tax/finance
compliance; analytics in anonymized form. Some data may be retained longer if
required for legal reasons or to resolve disputes. |
We will retain your personal data for as
long as necessary to fulfill the purposes outlined in this Privacy Policy or
until you request the deletion of your account, whichever comes first.
Specific retention periods include:
·
User account
data: Retained until account deletion.
·
Payment and
transactional data: Retained
for seven (7) years for compliance with financial and tax regulations.
·
Analytics
and usage data: Retained in
anonymized form for business purposes.
·
App Contacts: as
long as you maintain the contact in your App Contacts.
You may request account deletion by
contacting our support team via chat in the App or on our website. If the chat
is not available, you may contact us at second-phone-support@municorn.com or
using the in-app functionality.
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TL;DR:
The
Second Phone App is global, so your data may be transferred outside your
country (primarily to the US). For transfers from the EEA/UK to countries
without an adequacy decision we use the EU Standard Contractual Clauses and
the UK Addendum / IDTA as safeguards. |
Second
Phone is a global App. To operate our Services, your Personal Data may be
transferred, stored, and processed in jurisdictions outside of your country of
residence, primarily in the United States. Data protection laws in these
countries may differ from the laws of your country of residence.
We use
third-party service providers that operate global networks of data
centers for hosting and infrastructure purposes. As a result, the processing
of your Personal Data may be carried out in various locations, which is a
necessary part of providing the Services to you.
Where required under the EEA GDPR,
in case of transfers of personal data from the EEA to countries outside the
EEA, where we cannot rely on adequacy decisions adopted by the European
Commission (for more information, please see here) we ensure appropriate safeguards are in place to guarantee the
continued protection of your personal data, particularly by signing the
Standard Contractual Clauses of the European Commission (article 46(2)(c)
GDPR). For more information on these Standard Contractual Clauses, please
see here.
Where required under the UK GDPR, in
case of transfers of personal data to countries outside the United Kingdom, we
ensure appropriate safeguards are in place to guarantee the continued
protection of your personal data, particularly by signing the UK Addendum to
the EU Standard Contractual Clauses or the UK International Data Transfer
Agreement, whichever is more appropriate in the given situation. For more
information on UK Addendum and the UK International Data Transfer Agreement
please see here. We may also guarantee the protection of your personal data by
relying on adequacy decisions adopted or approved by the authorities in the
United Kingdom.
For further information, please
contact our support team via chat in the App or on our website. If the chat is
not available, you may contact us at second-phone-support@municorn.com.
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TL;DR:
The
App is not directed at children under 13 (US) or under 16 (EEA/UK). We do not
knowingly collect data from minors and will
delete it if discovered. |
Second
Phone App is not intended for or directed at children under the age of 13 in
the U.S. or 16 in the EEA/UK. We do not knowingly collect personal data from
individuals under these ages.
If you are under 13 in the U.S. or 16 in the EEA/UK, do
not: (i) use or provide any information in Second Phone App or through any of
its features, or (ii) provide any information about yourself to us, including
your name, address, telephone number or email address.
If you are
a parent or guardian and believe we have collected data from your child, please
contact our support team via chat in the App or on our website. If the chat is
not available, you may contact us at second-phone-support@municorn.com, and we will promptly delete such data.
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TL;DR:
We
are not responsible for the privacy practices of third-party websites and
services linked from the App. Read their privacy policies before sharing your
data with them. |
We are not responsible for the
practices employed by any websites or services linked to or from Second Phone
App, including the information or content contained within them. Where we have
a link to a website or service, linked to or from Second Phone App, we
encourage you to read the privacy policy stated on that website or service
before providing information on or through it.
General contact details. If you have
any questions about this Privacy Policy or Second Phone App, please contact us
via email at second-phone-privacy@municorn.com.
Data
protection officer. If you are an individual in
the EEA or the UK and you wish to exercise your rights under Section 7: Your Rights In Relation to Your Personal Data, or you have any questions about this Privacy Policy or Second
Phone App, you can contact our data protection officer via email at second-phone-privacy@municorn.com.
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TL;DR:
We
may update this Privacy Policy from time to time. The effective date at the
top will reflect any changes. For changes that affect your rights, we will
ask for your consent separately. |
The date this Privacy Policy was
last revised is indicated at the top of the page. We modify or update this
Privacy Policy from time to time. Some changes do not require your consent.
However, if we determine that the changes may pose a risk to your rights and
freedoms, we will ask for your consent to those changes separately from this
Privacy Policy.